GCDMP©

Risk-Based Clinical Data Management

Authors: , , , , , , , , , , , , , ,

Abstract

This chapter aims to define principles and best practices for applying risk-based approaches within Clinical Data Management (CDM). These principles are grounded in evolving regulatory expectations.

Starting over a decade ago, regulators have issued guidance documents advocating for the adoption of risk-based and fit for purpose approaches. The good clinical practice (GCP) guideline from the International Council for Harmonisation (ICH), commonly referred to as ICH E61, was updated in 2016 and 2025 to reinforce this direction.

Additionally, the ICH guideline on General Considerations for Clinical Studies (ICH E8)2 emphasized quality by design (QbD), which is grounded in two foundational risk-based principles: Prospectively identifying factors critical to quality and applying risk-based approaches to study design, conduct, monitoring, and reporting. This includes the use of risk-based approaches to quality management throughout the clinical study lifecycle to support the reliability of study results and the protection of participants.

Having already implemented risk-based approaches in the site monitoring and system validation spaces for many years, our traditionally risk-averse industry has become more familiar with strategies that align efforts with the risks to study participants’ rights, safety, and well-being and to data quality. As of 2021, 88% of clinical studies had implemented at least one component of risk-based quality management (RBQM) compared to 53% in 20193.

Considering the regulatory evolution and the need to accelerate the development of medicines, it is imperative for organizations managing clinical data and related systems to adopt QbD, RBQM, and fit for purpose principles, focusing on what matters most to participants’ protection and to the reliability of study results.

Keywords: Risk-Based Clinical Data Management, Clinical Data Science, Critical to Quality Factors, Quality by Design, Risk-Based Quality Management

How to Cite: Nadolny, P. , Celingant, C. , Christianson, L. , Kalra, P. , King, S. , Pollard, N. , Rieske, J. , Rowe, J. , Okewole, N. , You, D. , Das, D. , Hayden, E. , Klein, K. , Cesario, L. & Vazquez, M. (2026) “Risk-Based Clinical Data Management”, Journal of the Society for Clinical Data Management.(4). doi: https://doi.org/10.47912/jscdm.524

1) Learning Objectives

After reading this chapter, the reader will be able to:

2) Introduction

This chapter covers how Clinical Data Management (CDM) can evolve from traditional, reactive quality control (QC)-based strategies to proactive, end-to-end Quality Management within a risk-based quality management (RBQM) framework. This risk-based CDM (rb-CDM) evolution should begin with the adoption of foundational principles of quality by design (QbD), and progressively expand to apply RBQM cross-functionally, meaning:

This risk-based framework, including the activities outlined above, enables CDM to effectively implement risk-based study execution strategies and continuous process improvement to support the delivery of quality data sufficient for reliable and timely decision-making.

This means moving from reactively catching mistakes to proactively identifying problems that may jeopardize the outcome of a study. Overall, the end-to-end management of the operational and scientific risks should be embedded throughout the entire CDM Framework, with strong collaboration with other functions and disciplines involved in the process when necessary.

Organizational structures and functional responsibilities for risk-based activities may vary across companies. This chapter does not prescribe specific ownership of these activities. In practice, responsibilities such as risk identification, de-risking, and ongoing oversight may be performed by or shared with other functions (e.g., central monitoring, clinical operations), depending on the organization’s operating model.

Accordingly, this chapter emphasizes the principles and activities associated with risk-based approaches rather than their allocation to specific roles, allowing for flexibility in implementation across different organizational contexts.

In the absence of a robust body of knowledge and a comprehensive literature base regarding rb-CDM in clinical trial study execution, this content was gathered from regulations considered as minimum standards as well as feedback and insights from early adopters, regulators, and industry leaders to recommend best practices through a consensus-based methodology. As rb-CDM matures, new/revised regulations and guidances emerge, and technology evolves, we anticipate that the body of knowledge on this topic will blossom and lead to further evolution of this Good Clinical Data Management Practice (GCDMP) chapter and the overall SCDM Competency framework.4

This GCDMP chapter applies to all types of studies, whether interventional or non-interventional, and to all categories of medicinal products, including drugs, devices, and biological products.

The authors have made efforts to standardize terminology throughout the document while preserving the original language of cited regulations. When directly quoting regulatory documents, the original regulation’s terminology has been retained to ensure accurate attribution and to preserve the integrity of this chapter.

Below are some terminology-related conventions used in this paper:

3) Scope

3.1) In Scope

This GCDMP chapter provides guidance on the principles, standards, and practical applications of rb-CDM across the lifecycle of clinical studies. It is intended for sponsors, Clinical Research Organizations (CROs), service providers, regulators, and other stakeholders involved in the design, conduct, oversight, and reporting of clinical research. The chapter applies to all types of clinical studies, including interventional and non-interventional research as well as all categories of medicinal products such as drugs, devices, and biological products. The scope encompasses both organizational and study-level practices, emphasizing the integration of QbD, RBQM, and fit for purpose strategies to safeguard participant protection and ensure reliable, high-quality data.

This guidance defines the minimum expectations for applying risk-based principles to CDM, while recognizing that implementation should be flexible, context-dependent, and proportionate to study-specific risks. It is not intended to prescribe rigid operational procedures but rather encourages adoption of a pragmatic, critical-thinking mindset that prioritizes what matters most to participant rights, safety, and well-being, and to the credibility of study results. As such, this document provides a framework that organizations can adapt and evolve as regulations mature, technology advances, and industry experience with rb-CDM expands.

3.2) Out of Scope

Detailed risk identification methodologies (statistical or non-statistical, technology-based or manual), as well as system-specific lifecycle activities (e.g., selection, validation, and use), are out of scope for this chapter.

Additionally, this chapter does not address broader operational and organizational frameworks, including standard operating procedure (SOP) lifecycle management, change management, and service provider management. These topics may be covered in dedicated SCDM publications (e.g., GCDMP chapters, topic briefs) and should be consulted as appropriate. This chapter should therefore be read in conjunction with other GCDMP chapters, particularly those related to data quality, to ensure a comprehensive understanding of integrated quality management.

4) Minimum Standards

In GCDMP chapters, regulations are considered minimum standards to be met and followed. For this chapter on rb-CDM, important applicable passages have been drawn from the following six regulatory guidances, listed chronologically:

To ease the reading of this GCDMP chapter, those passages have been included in Appendix A and organized around six core concepts introduced in this section.

4.1) Risk-based approaches

Risk-based approaches are practices that proportionally align focus and efforts on what matters most to prevent and manage risks to 1) participant’s rights, safety, and well-being; 2) critical data, processes, and systems; and 3) the reliability of study results considering the likelihood of risk occurrence, their severity and potential detectability.

In CDM, a risk-based approach may focus monitoring and validation on data and processes that directly affect reliability of study results (e.g., primary efficacy and safety endpoints and other critical efficacy variables) or participant’s protection (e.g., eligibility criteria confirmation data, investigational product (IP) dosing data as recorded in the electronic data capture (EDC) system), while applying a risk-adapted oversight to data not associated with CtQ Factors.

4.2) Fit for purpose considerations

Fit for purpose clinical study quality means that the study should be of sufficient quality to meet its objectives, provide confidence in the study’s results, and support sound decision-making, all while adequately protecting the participants involved. As such, regulations, and especially ICH E6 (R3),1 emphasize risk-proportionate strategies that support quality throughout the study.

4.3) Data Integrity and Quality

The authors acknowledge that there is no industry-wide or regulatory-aligned definition that clearly distinguishes data quality from data integrity, and that these concepts are inherently overlapping. Consistent with prior SCDM publications, this section does not aim to establish prescriptive or universally accepted definitions. Instead, it provides an operational perspective to support the evolving role of CDM toward clinical data science (CDS), where emphasis is placed on risk-based approaches and in ensuring the reliability of trial results, rather than solely focusing on managing data appropriately.

As stated in SCDM’s 2022 “The evolution of Clinical Data Management into Clinical Data Science”, “Clinical data management is primarily focused on data flows and data integrity (i.e., data is managed the right way). Clinical Data Science broadens this focus by adding the data risk, data meaning and value dimensions for achieving data quality (i.e., data is credible and reliable).”9

Understanding the difference between data integrity and data quality is critical for CDM professionals, as it is at the core of the evolution of CDM into CDS.

The introduction to MHRA’s guidance on GxP Data Integrity6 states that data integrity is not data quality since “the controls required for integrity do not necessarily guarantee the quality of the data generated.”6

First, “Data integrity is the degree to which data are complete, consistent, accurate, trustworthy, reliable and that these characteristics of the data are maintained throughout the data life cycle. The data should be collected and maintained in a secure manner, so that they are attributable, legible, contemporaneously recorded, original (or a true copy) and accurate.”6 This MHRA definition is consistent with the ALCOA (Attributable, Legible, Contemporaneous, Original and Accurate) principles.

Note the term “certified copy” in ICH E6 (R3)1 aligns with the MHRA’s use of “true copy,” since both are defined as an accurate, verified reproduction of the original record.

Data quality is “the assurance that data produced is exactly what was intended to be produced and fit for its intended purpose. This incorporates ALCOA.”6

Data quality is a broader and more comprehensive goal—it is “fit for purpose.” In the context of clinical studies, data should be fit for purpose and adhere to the definition in Section 4.2.

At its core, “fit for purpose” data quality recognizes that no study is conducted perfectly. Striving for perfection may not be realistic or necessary; what truly matters is avoiding errors that could meaningfully affect participant protection or compromise the reliability of study results. Achieving fit for purpose quality therefore requires a pragmatic, risk-proportionate approach, ensuring that efforts are focused on study attributes that are critical to the protection of participants and the reliability of study results.

It is helpful to consider that the quality of clinical data during study execution is dependent on two distinct steps:

Data integrity—which has traditionally been the primary focus of data management activities—covers this second stage but generally not the first. Monitoring the reliability of the first stage was traditionally considered outside of the scope of CDM.

In conclusion, we could conceptually differentiate data quality vs. data integrity as follows:

Data integrity means that the data are managed the right way.

Data quality means that the data are reliable and fit for purpose for decision making.

4.4) Quality by Design (QbD)

ICH E8 (R1)2 states that “QbD in clinical research sets out to ensure that the quality of a study is driven proactively by designing quality into the study protocol and processes.”2 This involves the use of a prospective, cross-functional (e.g., clinical operations, quality, data management, biostatistics) and multidisciplinary (i.e., across different areas of expertise such as sponsors, CROs, technology providers, clinical investigators, patients, patient advocates, and healthcare providers) approach to promote the quality of protocol and process design (at study, program and overall organizational level) in a manner proportionate to the risks involved, with clear documentation and communication on how this will be achieved.

4.5) Critical to Quality Factors (incl. Critical Data and Processes)

The ICH E8 guidance states that “The quality by design approach to clinical research involves focusing on CtQ factors”2 and defines them as “attributes of a study whose integrity is fundamental to the protection of study participants, the reliability and interpretability of the study results, and the decisions made based on the study results.”2 In addition, CtQ factors should be considered holistically, so that dependencies among them can be identified and managed appropriately. Understanding these interdependencies is essential for designing a robust, efficient quality management approach aligned with QbD principles. Furthermore, the quality management approach should be proactively integrated into the operational plans ensuring that quality is not only conceptualized but also embedded in the design, conduct, oversight and monitoring of the clinical study.

Refer to Table 1 for an example of CtQ factors representing critical data and processes to consider (see section 4.6).

Table 1: CTTI Critical to Quality Categories and Factors.1

CtQ Categories CtQ factors
Protocol Design Eligibility Criteria
Randomization
Masking
Types of Controls
Data Quantity
Endpoints
Procedures Supporting Study Endpoints and Data Integrity
Investigational Product (IP) Handling and Administration
Feasibility Study and Site Feasibility
Accrual (i.e., Enrollment Strategy)
Patient Safety Informed Consent
Withdrawal Criteria and Trial Participant Retention
Signal Detection
Safety Reporting
Data Monitoring Committee (DMC)/Stopping Rules (if applicable)
Study Conduct Training
Data Recording and Reporting
Data Monitoring and Management
Statistical Analysis
Study Reporting Dissemination of Study Results
Third-party Engagement Delegation of Sponsor Responsibilities and Collaborations
  • Note: The CTTI introduced the CtQ factors in 2015 and organized them around the six major categories below. Those can be used as a guide to define the study specific CtQ Factors.10

4.6) Risk Management

Risk management is a systematic approach to managing risks. It includes the identification, assessment, monitoring, mitigations, controls, communications, and evaluation of risks throughout the lifecycle of a clinical study (Refer to Section 5.3 for detailed considerations regarding Risk management).

5) Best Practices

With these guidances in mind, we recommend the following best practices for applying a risk-based approach within CDM.

  1. Manage risk through a multidisciplinary approach supported by management. [VI]

  2. Embed quality at the design stage through critical thinking. [VI]

  3. Engage all external parties in risk identification and mitigation. [VI]

  4. Keep risk control proportionate, with risk-surveillance strategies defined prospectively, including relevant KRI triggers and pre-specified acceptable ranges such as QTLs. [VI]

  5. Focus data integrity assessments on CtQ factors, critical risks, and critical processes. [VI]

  6. Review and adapt risk assessments dynamically throughout study conduct. [VI]

  7. Communicate and report risks, quality issues, and remedial actions to stakeholders. [VI]

  8. Conduct a final risk assessment at close-out and feed lessons learned into corrective actions and preventive actions (CAPAs) and future studies. [VI]

5.1) Summary of Best Practices

The best practices detailed throughout this section can be summarized as follows. They follow the rb-CDM life cycle, from organizational foundations through study design, conduct, and close-out. Each practice is elaborated in the subsections indicated in Table 2.

Table 2: Good Clinical Data Management Practices (GCDMP) Evidence Grading Criteria.

Evidence Level Evidence Grading Criteria
I Large, controlled experiments; meta, or pooled analysis of controlled experiments; regulations or regulatory guidance
II Small controlled experiments with unclear results
III Reviews or syntheses of the empirical literature
IV Observational studies with a comparison group
V Observational studies, including demonstration projects and case studies with no control
VI Consensus of the writing group, including GCDMP Editorial Board and public comment process
VII Opinion papers
  • Each best practice above is followed by an evidence level grade. Evidence supporting assertions or otherwise informing practice recommendations in GCDMP chapters is graded according to the strength of the evidence. The GCDMP has adopted the grading criteria in the Evidence Classification Table. The strength, also referred to as level of evidence, is based on the amount of evidence – such as the number of studies supporting a result, as well as the extent to which the study designs support causal inference

5.2) Overall rb-CDM Framework considerations

It is essential to recognize that quality in clinical studies is multi-dimensional, bringing together QbD and RBQM, which complement each other to ensure fit for purpose study quality. Within this broader, cross-functional and multidisciplinary quality framework, rb-CDM serves as a key component that contributes to both QbD and RBQM.

A critical concept underpinning this quality framework is fit for purpose clinical study quality, as defined in Sections 4.2 and 4.3: rather than striving for perfection in every aspect of a study, efforts should be focused on the study attributes that are critical to the protection of participants and the reliability of study results.

In essence, QbD establishes the foundation for clinical study quality by proactively identifying and embedding quality into the study from the outset, during the study design and planning stage, using sound scientific understanding and proactive risk management. This approach enables sponsors to “de-risk” the protocol upfront by identifying CtQ factors and potential risks to those factors, ensuring that the study design is optimized to prevent foreseeable issues.

RBQM builds on this foundation by applying risk assessments and mitigation strategies throughout study conduct, ensuring that risks are continuously evaluated and that risk controls remain appropriate and are adapted dynamically as the study progresses.

Quality should be embedded from the study design stage through critical thinking. This requires anticipating issues before they occur by evaluating trial activities from multiple perspectives—scientific, operational, and regulatory.

Critical thinking enables proactive, risk-based quality management by:

To support this mindset, flexible and targeted quality oversight approaches should be implemented through predefined, risk-based strategies and continuously refined throughout the study.

This quality framework operates at both an organizational and a study level. At an organization level, “the sponsor should implement an appropriate system to manage quality throughout all stages of the trial process.”1 At a clinical study level, it includes “the design and implementation of efficient clinical trial protocols, including tools and procedures for trial conduct (including for data collection and management), in order to ensure the protection of participants’ rights, safety and well-being and the reliability of trial results.”1 As illustrated in rb-CDM Framework in figure 1 below, these four dimensions—Quality by Design and RBQM, applied across both the organization and study levels—must be considered together to establish a robust rb-CDM framework that aligns with risk-based quality management practices.

Figure 1: rb-CDM Framework.

This risk-based quality framework moves beyond tools and checklists to foster prospective planning, critical thinking, and flexible, proactive, study-specific strategies in study design and conduct. It explicitly discourages one-size-fits-all approaches, advocating instead for tailored, risk-proportionate strategies that support quality throughout the study.2

The QbD process should be led by a cross-functional, multidisciplinary team—for example, representatives from clinical operations, data management, biostatistics, medical, regulatory affairs, pharmacovigilance, digital data technology (or equivalent), drug supplies, and quality assurance—with each discipline bringing a unique perspective to identify CtQ factors and potential risks. These teams collaboratively define quality objectives, risk mitigation strategies, QTLs, and KRIs. Engaging external stakeholders (e.g., patients, patient advocacy groups, healthcare providers, and clinical investigators) is equally vital to ensuring that clinical studies are scientifically valid, operationally feasible, ethically sound, and patient-centered. Organizational adoption of this collaborative model is detailed in Section 5.3.

In summary, the overall quality framework applies to all drug development stakeholders involved and aims to ensure participant protection and the reliability of study results throughout the clinical study lifecycle (i.e., starting from protocol design and extending through study conduct, evaluation, and reporting phases). Important risks that cannot be eliminated through study design may be mitigated and managed through the study’s operational plans, processes, and procedures. These plans, processes, and procedures should be implemented in a way that is proportionate to the risks to study participants and the importance of the data collected.

5.3) Organizational considerations

As discussed, Risk Management (including QbD and RBQM) and its rb-CDM component should ideally be recognized as a multidisciplinary and cross-functional responsibility supported by a leadership-driven culture in which critical thinking and open, proactive dialogue about what is critical to quality are valued and rewarded2 (see also Section 6.3). It is therefore recommended to follow a systematic, cross-functional approach to define and embed the right culture, policies, processes and training in order to adopt new ways of working, build new skills, prevent siloed RBQM delivery, and build trust in new tools and techniques.

Below are some of the elements that could be considered when creating an RBQM framework, with a particular emphasis on rb-CDM:

Note: Consider leveraging established industry references such as:

5.4) Study Level considerations

Figure 2 highlights the core elements, organized across eight steps, to implement a study level rb-CDM life cycle framework.

It illustrates the iterative process flow of the rb-CDM life cycle, beginning with Quality by Design (QbD) and progressing through risk management steps mentioned in ICH E6 (R3).1 Each element in the figure corresponds to process steps described in Section 6.1 below, providing a visual anchor for understanding the integration of risk-based approaches at the study level.

Figure 2: rb-CDM Study Life Cycle.

First and foremost, even though this GCDMP chapter focuses on rb-CDM, it is essential that all risk management related activities incorporate input from the cross-functional and multidisciplinary team described in Section 5.2, representing all critical disciplines and functions involved in the study.

This collaborative approach should be applied regardless of the operational model—whether in-house or outsourced—ensuring comprehensive expertise and alignment throughout the rb-CDM process.

It is essential to consider all external parties (e.g., CROs, technology and service providers) as risk identification should “be considered across … service provider activities)”1 and risk mitigation “activities may be incorporated, for example, in … agreements between parties defining roles and responsibilities.”1

When engaging with external parties in risk management activities, the following elements should be considered:

The rb-CDM Life Cycle focuses on core data-related components within the QbD and RBQM framework. Aligned with the ICH E6 (R3),1 it begins with QbD by identifying CtQ factors and associated risks, followed by the six risk management steps described in its section 3.10.1, “Risk Management.”

It is important to note that while the rb-CDM life cycle follows a structured framework, its implementation must be customized to the specific needs of each study. Factors such as therapeutic area, study design complexity, data sources, and participant population should inform the prioritization and execution of risk management activities.

This approach ensures that data quality is proactively designed and continuously monitored throughout the clinical study lifecycle, supporting regulatory compliance and improving patient protection and data reliability.

Table 3 relates the eight lifecycle steps shown in Figure 2 to the six risk-management steps of ICH E6(R3) section 3.10.1 and to the Section 6 stage at which each is implemented. It provides a single reference point that links the QbD/RBQM lifecycle, the regulatory risk-management process, and this document’s stage-based guidance.

Table 3: Best practices and corresponding chapter sections.

# Best Practice Life Cycle Phase Elaborated In Regulatory Basis (App. A)
1 Multidisciplinary risk management supported by management Foundational 5.2, 5.3 A.6
2 Quality embedded at the design stage through critical thinking Set-up 5.2 (QbD), 6.1 A.1, A.4
3 External parties engaged in risk identification and mitigation Foundational/Set-up 5.2, 5.4, 6.1 A.6
4 Proportionate risk control with prospectively defined surveillance strategies and applicable thresholds Set-up 5.4 (risk control), 6.1 A.5, A.6
5 Data integrity assessments of CtQ factors, critical risks, and critical processes Execution 4.3, 5.4, 6.1 A.3, A.5
6 Dynamic review and adaptation of risk assessments during study conduct Execution 5.4 (risk review), 6.1 A.6
7 Risk communication and reporting to stakeholders and in the clinical study report Execution/Close-out 5.4 (risk communication and reporting) A.6
8 Final risk assessment at close-out, with lessons learned feeding CAPAs and future studies Close-out 6.1, 6.3 A.6

This crosswalk represents an illustrative mapping of the rb-CDM lifecycle to the ICH E6(R3) risk-management framework and should not be interpreted as a regulatory classification of the individual lifecycle steps.

The considerations below combine regulatory requirements with recommended rb-CDM best practices. Unless explicitly attributed to a regulatory source, additional operational practices should be interpreted as recommendations rather than direct regulatory requirements.

Each of these steps is described in detail below:

1. Risk Identification: Identify risks that may have a meaningful impact on CtQ factors prior to study initiation and throughout study conduct. “Risks should be considered across the critical processes and systems,” that matter most to the overall reliability of trial results and participant safety, “including computerized systems used in the clinical trial (e.g., trial design, participant selection, informed consent process, randomization, blinding, investigational product administration, data handling and service provider activities).”1

Although this list may not represent a complete set of considerations, it provides a strong starting point. Organizations should also evaluate additional factors that are specific to the study protocol or informed by prior experience. These may include:

2. Risk Evaluation: Assess the identified risks—and existing controls in place—to mitigate the risk considering its likelihood of occurrence, its detectability and its impact.

3. Risk Control: Establish robust risk-proportionate approaches to monitoring, validation, and management of risks to the CtQ factors (i.e., critical data, processes, and systems) while remaining flexible and adaptive to emerging risks. Those risk-proportionate controls should be fit for purpose—reflecting the importance of the data—in ensuring participant’s protection and the reliability of study results.

The distinction between critical and non-critical data is not strictly binary. Organizations may implement a tiered classification framework, assigning varying levels of criticality based on the importance of the data within the trial; that is the extent to which errors could impact on participant’s protection, the reliability of study results, and decision-making. The rb-CDM process shall be adjusted accordingly considering risk proportionality to each defined tier.

This entails incorporating feedback from study personnel, healthcare providers, participants, and participant advocates in the study design to reduce unnecessary protocol complexity, for example by eliminating the collection of non-essential data, by simplifying and/or reducing visit schedules and study procedures, and by leveraging technology for data collection.

Implement cross-functional mitigation strategies to manage risks. This includes leveraging clinical data and metadata to identify emerging risks during study conduct through the use of KRIs, QTLs, and other data-driven approaches, such as data analytics and automated data validations, to flag inconsistencies and missing data patterns.

4. Risk Communication: Communicate risk-related information among all parties involved in the study so that the risks that matter and the controls in place are commonly understood and acted upon.

5. Risk Review: Risk review is the ongoing, cross-functional re-evaluation of the CDM/CDS-identified risks and their CtQ factors—confirming that existing controls remain effective and detecting new or evolving risks as data accumulate over the course of the study.

6. Risk Reporting: Risk reporting documents and communicates the rb-CDM risk-management approach and its outcomes—including important quality issues and any QTL breaches—to the study team, functional and sponsor governance, and, through the clinical study report (CSR), health authorities.

6) rb-CDM Process Implementation Considerations During Different Stages of Protocol Development

The adoption of rb-CDM approaches has a deep impact on our traditional CDM ways of working, as shown in the process flows in this section. Throughout this section, examples of process flows have been provided in which risk-based process steps (in green) have been added to the traditional CDM steps (in blue) to illustrate the end-to-end nature of risk-based approaches.

6.1) Risk Based Considerations During Study Design and Study Planning

Figure 3: Example of rb-CDM Set-Up Process.

The Study Design and Planning steps shown in Figure 3 have also been summarized as a checklist in Appendix B.

Risk Identification, Operational Feasibility and Risk Assessment

Risk management is a core component of QbD and RBQM, encompassing the proactive identification, assessment, and control of risks throughout the clinical study lifecycle. It begins with risk prevention, by identifying threats prior to the first patient being enrolled into the study, which have the potential of leading to errors that could negatively impact patient protection, the credibility and reliability of the study results. As such, a sound scientific protocol, operationally feasible and without unnecessary burden to sites and patients, is the foundation of study execution.

First and foremost, it is critical to engage the appropriate cross-functional, multi-disciplinary, internal and external experts to manage all risks through their entire life cycle.

Engage Stakeholders and Align on Protocol Design

Identify and Document Critical to Quality (CtQ) Factors

Table 4: rb-CDM Lifecycle Crosswalk.

Lifecycle step (Figure 2) Main Objective ICH E6(R3) Implemented in
1. Identify CtQ Factors QbD Risk Identification 6.1
2. De-risk Study QbD Risk Identification + Risk Control (by design) 6.1
3. Define Mitigation & Monitoring Strategies (QTLs, KRIs) RBQM Risk Evaluation + Risk Control 6.1–6.2
4. Implement Mitigation & Monitoring Strategies RBQM Risk Control 6.2
5. Monitor Risks RBQM Risk Review + Risk Communication 6.2
6. Correct Improvement loop Risk Control (corrective) 6.2–6.3
7. Learn Improvement loop Risk Review 6.3
8. Adapt Improvement loop Risk Review 6.3
  • Note: Risk Communication and Risk Reporting are cross-cutting. Communication runs throughout the lifecycle (the center of Figure 2), while Reporting concentrates at close-out (Section 6.3 and the clinical study report).

Conduct Study Risk Assessment

While many risks would be evaluated and accounted for by the multidisciplinary and cross-functional study team, some risks related to areas such as the 5Vs of the clinical data13 (i.e., Volume, Variety, Velocity, Veracity, and Value), the data flow’s complexity, the extent of service providers involved, and planned technologies used through the data life cycle would be the primary focus of CDM.

Protocol De-Risking

Define Mitigations and Surveillance Plans for Remaining Risks: Design Data Review and Validation Strategy

Develop a cross-functional, multidisciplinary and CDM-specific data review and validation strategy proportionate to risks.

Note: While this GCDMP chapter focuses on rb-CDM, the parallels between SDV and data review are important to highlight. Increasingly, CDM organizations are configuring EDC systems to dynamically adjust SDV requirements based on strategies outlined in the study monitoring plan. As a result, CDM subject matter experts (SMEs) should have a clear understanding of the SDV process and its implications for overall data quality.

Important considerations

Some publications, such as the 2014 TransCelerate publication on “Evaluating Source Data Verification as a Quality Control Measure in Clinical Trials”15 and the 2021 SCDM publication on “Risk-based Quality Management in CDM”16 have highlighted that Queries and SDV seem to have a low impact on study data corrections and study results, when evaluated as an overall study measure (e.g., as study level QTL).

Those publications showed that at study level, the industry median of eCRF data correction due to SDV was only 1.1%14 and those from auto-queries varied from 0.9%15 to 1.4%.14

This does not suggest that SDV and query management lack value or should be eliminated from our traditional processes. With 100% SDV, all mistakes can theoretically be corrected. However, when assessing data corrections following SDV, at eCRF forms, sites, countries and Therapeutic Areas (TAs) level, it could highlight variability in the rate of data corrections across those dimensions. As an example, the median of eCRF data change rate due to SDV in Oncology was 2.7%14 and only 0.5% for Pharmacokinetic studies.14

So, while a study may show an overall low data change rate resulting from SDV, some sites may exhibit significantly higher rates—indicating potential issues with source data control. It means that correcting all transcription errors through SDV is not addressing the root cause, but only correcting errors retrospectively.

An efficient risk-adapted SDV approach should prioritize evaluating whether data quality meets predefined targets, rather than simply correcting individual transcription errors. It relies on a meaningful, data-driven sampling strategy to assess quality at both the study and site levels. When deficiencies are identified, proportionate corrective actions should follow to safeguard overall data integrity. Risk-adapted SDV is not designed as a mechanism for fixing isolated transcription errors; rather, it serves to detect and address underlying, systematic issues that require resolution.

Risk-based SDV and query strategies should therefore ensure focus on activities where they are most needed, proportionally to risks, without compromising data quality or patient protection.

As such, a sound approach should therefore apply proportionate SDV based on objective (i.e., data and fact driven) information such as (but not limited to):

Note: Site monitoring frequency should not be dictated by SDV efforts. A risk-based SDV approach does not necessarily mean fewer site monitoring visits, either on-site or remote, but rather a shift in focus to critical risk areas (e.g., SDR, protocol compliance, adherence to procedures). Frequency of monitoring visits may align with the minimum frequency necessary for broader oversight, with triggered monitoring visits based on findings and/or workload (e.g., SDR, drug reconciliation, etc.), beyond SDV alone.

Define Quality Control and Risk Mitigation Plan

Potential objectives of a risk-based audit trail review include:

Example use cases and risk scenarios include:

For a more comprehensive list of scenarios, please refer to appendix 3 of the SCDM and eClinical Forum Position paper on Audit Trail Review.17

Specify Reporting and Analytics Requirements

Implement Risk Control Strategies

Additional Considerations

Key Takeaway: These start-up activities position CDM experts as proactive risk managers and data quality stewards from the earliest study stages, aligning with risk-based and quality-focused study execution.

6.2) Risk-Based Study Execution Considerations

Figure 4: Example of rb-CDM Study Execution Process.

During the study execution phase, CDM experts should focus on the following key activities to ensure data quality and manage risks effectively. The Study Execution steps shown in Figure 4 have also been summarized as a checklist in Appendix C.

Monitor, Document and Address Observed Risks

Conduct tailored data review proportional to risk

Monitor trends in non-critical data as identified through the risk assessment (i.e., data not associated with CtQ, data related to tertiary efficacy)

Review critical data and associated metadata

Monitor for the possible emergence of any new risks

This includes, but is not limited to:

Monitor critical processes during study execution

Ensure synergetic oversight across stakeholders

Signal Review

Below are some examples of signals that can be found with the potential responses made by teams.

To address the examples above, the CDM SMEs and the study team should dig deep into the data to understand the root cause of the issues. They need to perform detailed root cause analysis (RCA) and data review findings to resolve them. Occasionally, the team will need to go through multiple iterations of RCA and follow-up to fully understand the root cause. This requires a focus on details and strong communication skills as most findings will not result in queries, but rather in addressing systematic process issues and site behaviors.

Adapt by Maintaining Dynamic Risk Management

Protocol Amendments or Major Study Updates (e.g., Urgent Safety Measures): Continuous Review and Protocol Amendments

Key Takeaway: These activities empower CDM experts to maintain proactive oversight of data quality, ensuring that critical data and processes are continuously monitored and managed in alignment with study risks.

6.3) Risk-Based Study Close-Out Considerations

Figure 5: Example of rb-CDM Study Closure.

At the close-out phase of a clinical study, CDM experts should ensure the following activities are completed to confirm data integrity, regulatory compliance, and risk mitigation. The Study Closure steps shown in Figure 5 have also been summarized as a checklist in Appendix D.

Conduct a Final Risk Evaluation

Assess Remaining Outstanding Issues

Review and close outstanding issues

Document process completion and compliance

Adapt Processes and Systems Based on Lessons Learned

Key Takeaway: These close-out activities ensure a high-quality, compliant database lock and clear documentation of risk management outcomes.

6.4) Practical rb-CDM Study examples for CDM Experts

The examples below are illustrative and do not represent an exhaustive identification of CtQ factors, risks, or mitigation strategies for the studies described.

Example #1: Age-Specific Protocols

Risk Identification and Risk Assessment
Selected CtQ factors may include the accuracy and consistency of the primary PRO endpoint (IBS-SSS), including diary compliance and handling of missing data. Assessments are added by age (a PRO at the age of 8, a second PRO at the age of 9, self-administration of IMP at the age of 12, a daily diary at the age of 13), but no new PROs are introduced beyond a participant’s first visit — so some participants miss PROs they would otherwise reach, leaving data gaps.
De-risk Study Considerations
Make the design participant-centric and adaptive — allow a baseline ePRO whenever a participant joins (not only at age 8), add a participant-burden check tied to a drop-out KRI, and review prior protocols for age-related deviations to inform QbD.
Define risk mitigation and Controls
Set age-specific KRIs on ePRO-completion compliance alongside a study-wide ePRO-compliance QTL.
Implement risk mitigation and Controls
Activate the QTL and KRIs; train site staff on the requirement; create age-appropriate data-entry guidance (an 8- and a 13-year-old differ cognitively); and add edit checks for a prior ePRO, ePRO reminders/prompts, and source-data-review checks.
Monitor risks
Watch for links between daily-ePRO inconsistencies and other compliance issues, and review the KRIs and QTL at the defined frequency, tracking trends over time.
Correct, Learn & Adapt
Document corrective actions (e.g., friendly ePRO reminders for 8-to-9-year-olds if compliance dips) and run a Plan-Do-Check-Act cycle to sustain data quality as participants age.
  • Note: IBS-SSS: Irritable Bowel Syndrome Severity Scoring System.

A pediatric inflammatory bowel disease study introduces PRO assessments at different ages, creating a data-collection risk.

Example #2: Endpoint-Specific Protocols

A Phase II study assessing the reduction in the rate of acute chronic obstructive pulmonary disease (COPD) exacerbations, where data quality depends on how exacerbations are reported.

CtQ Identification and Risk Assessment
Selected CtQ factors may include the accurate, consistent, and timely reporting of acute COPD exacerbations (investigator severity grading; patient symptom reporting via the EXACT eDiary and the CAT) plus upfront investigator training. Key risks: “acute worsening” lacks measurable thresholds (diagnostic variability), and the > =14-day rule between events can fragment a single ongoing episode.
De-risk Study Considerations
Simplify endpoint definitions and add technical controls — define worsening concretely (e.g., a > =2-point CAT increase within 48 hours), require real-time reporting, and count a new event only after symptoms return to baseline and remain stable for > =7 days.
Define risk mitigation and Controls
Design a KRI that calculates the rate of acute COPD exacerbations per participant-visit at each site to detect under- or over-reporting across sites and countries.
Implement risk mitigation and Controls
Program the KRI and data-quality assessment; assign the medical manager as primary reviewer; set triggers (low rates prompt eCRF-completeness checks, high rates prompt safety assessment); and review and refine thresholds throughout the study.
Monitor risks
Site A reported 0 exacerbations versus a study average of 0.64 per patient, across ~10 participants over three years.
A cross-functional review (Clinical Data Management, Medical Monitoring, and Project Management) examined four risk categories and identified two root causes:
  • Site process (the protocol was misunderstood, with inconsistent, subjective assessment) and

  • Data collection (inefficient workflows caused delayed or missing eCRF entries).

  • Participant-reporting and systemic/system causes were ruled out, because the issue was site-wide while other sites performed normally.

Correct, Learn and Adapt
Retrospectively document all missed cases from source data and eDiaries, and retrain the site on precise exacerbation identification, real-time reporting, and workflow optimization; reporting compliance improved and was sustained.
Refresh critical-process training regularly (not only at start-up), identify risks at protocol design to reduce complexity and site/participant burden, and make regular training standard practice as a preventive action.
  • Note: CAT: COPT Assessment Test.

6.5) Additional considerations

First and foremost, we need to clearly understand what adopting rb-CDM approaches means.

It evolves around adopting rb-CDM means applying the QbD and RBQM framework of Section 5 — embedding quality at design, focusing effort proportionately on what is critical, and running the six-step risk-management cycle (Section 5.4) within the cross-functional, critical-thinking culture described in Sections 5.2–5.3.

It does not mean:

7) SOP Considerations

The relevant SOP may vary from company to company. There might be an overarching SOP and then associated job aids or work instructions, or it may spread across various SOPs. However, the following areas should be covered by process document(s):

Purpose: Define a structured approach to identify, assess, and mitigate data-related risks.

Key Elements:

Purpose: Ensure the DMP reflects risk-based data strategies.

Key Elements:

Purpose: Define risk-informed approaches to data validation and review.

Key Elements:

Purpose: Standardize how potential data quality issues or anomalies are detected and acted upon.

Key Elements:

Purpose: Govern how emerging risks and deviations are investigated and managed.

Key Elements:

Purpose: Clarify classification, triage, and resolution of unexpected data issues.

Key Elements:

Purpose: Establish governance and ownership for ongoing risk-based data oversight.

Key Elements:

Purpose: Pre-database lock checks with risk-based quality control emphasis.

Key Elements:

Purpose: Ensure audit readiness and traceability of risk-based decisions and activities.

Key Elements:

Acronyms

Acronym Description
AE Adverse Event
ALCOA Attributable, Legible, Contemporaneous, Original and Accurate
CAPA Corrective Action and Preventive Action
CAT COPD Assessment Test
CDISC Clinical Data Interchange Standards Consortium
CDM Clinical Data Management
CDS Clinical Data Science
CMP Centralized Monitoring Plan
COPD Chronic Obstructive Pulmonary Disease
CRO Clinical Research Organization
CtQ Critical to Quality
CTTI Clinical Trial Transformation Initiative
DMP Data Management Plan
DSMB Data Safety Monitoring Board
DSUR Development Safety Update Report
eCOA electronic Clinical Outcome Assessment
EDC Electronic Data Capture
EMA European Medicines Agency
ePRO electronic Patient Reported Outcome
EXACT EXAcerbations of Chronic pulmonary disease Tool
FDA Food and Drug Administration
FHIR Fast Healthcare Interoperability Resources
GCDMP Good Clinical Data Management Practice
GCP Good Clinical Practice
HL7 Health Level Seven
IA Interim Analysis
ICH International Council for Harmonisation
IQRMP Integrated Quality Risk Management Plan
IRC Independent Review Committee
KRI Key Risk Indicator
KT Knowledge Transfer
PHE Public Health Emergency
QbD Quality by Design
QC Quality Control
QTL Quality Tolerance Limit
RACI Responsible, Accountable, Consulted & Informed
RACT Risk Assessment Categorization Tool
rb-CDM risk-based Clinical Data Management
RBQM Risk-Based Quality Management
RCA Root Cause Analysis
SCDM Society for Clinical Data Management
SDR Source Data Review
SDV Source Data Verification
SME Subject Matter Expert
SOP Standard Operating Procedure
TA Therapeutic Area

Appendix A – The Minimum Standards (i.e., Regulations)

Important passages from the following six regulatory guidances have been summarized below and organized around six main concepts:

Regulations

Topics:

Some regulatory sections apply to multiple concepts and may be repeated in each table where necessary.

A.1 Risk-Based Approaches

Regulation/Guidance Section # Section Name Regulatory Concept
FDA, April 2023, RBM Q&A II Background “Sponsors should implement a system to manage, throughout all stages of the clinical investigation, both risks to participants (e.g., a safety problem) and to data integrity (e.g., incomplete and/or inaccurate data).”
FDA, August 2013, A Risk-Based Approach to Monitoring B Rationale for RBM “There is a growing consensus that risk-based approaches to monitoring, focused on risks to the most critical data elements and processes necessary to achieve study objectives, are more likely than routine visits to all clinical sites and 100% data verification to ensure subject protection and overall study quality.”
FDA, August 2013, A Risk-Based Approach to Monitoring II Background “A risk-based approach to monitoring does not suggest any less vigilance in oversight of clinical investigations. Rather, it focuses sponsor oversight activities on preventing or mitigating important and likely risks to data quality and to processes critical to human subject protection and trial integrity.”
ICH E6 R3, January 2025 I Introduction ICH E6 (R3) “builds on key concepts outlined in ICH E8(R1) General Considerations for Clinical Studies. This includes fostering a quality culture and proactively designing quality into clinical trials and drug development planning, identifying factors critical to trial quality, engaging interested parties, as appropriate, and using a proportionate risk-based approach” and “encourages a risk-based and proportionate approach to the conduct of a clinical trial.”
ICH E6 R3, January 2025 II Principles of ICH GCP “Clinical trial processes and risk mitigation strategies implemented to support the conduct of a trial should be proportionate to the importance of the data being collected and the risks to trial participant safety and data reliability. Clinical trial processes and risk mitigation strategies implemented to support the conduct of the trial should be proportionate to the importance of the data being collected and the risks to trial participant safety and the reliability of trial results.” Furthermore, “The overarching principles provide a flexible framework for clinical trial conduct.”
ICH E6 R3, January 2025 II (Sub-Section 6) Principles of ICH GCP This section emphasizes the need to focus on “the protection of participants, the reliability and interpretability of the trial results and the decisions made based on those trial result,” quality by design, and the use of risk-based approaches. Additionally, “Factors critical to the quality of the trial should be identified prospectively,” and “Strategies should be implemented to avoid, detect, address and prevent serious non-compliance with GCP, the trial protocol and applicable regulatory requirements.”
ICH E8 R1 October 2021 3.1 Quality by Design of Clinical Studies “The likelihood that a clinical study will answer the research questions while preventing important errors can be dramatically improved through prospective attention to the design of all components of the study protocol, procedures, associated operational plans and training.” The paragraph continues in questioning the robustness of traditional processes mentioning that “activities such as document and data review and monitoring, where conducted retrospectively, are an important part of a quality assurance process; but, even when combined with audits, they are not sufficient to ensure quality of a clinical study.”
ICH E8 R1 October 2021 3.3.1 Establishing a Culture that Supports Open Dialogue “Establishing a Culture that Supports Open Dialogue” sets a fundamental shift in our approaches to conducting clinical trials. It signifies the end of one-size-fits all. It states “Creating a culture that values and rewards critical thinking and open, proactive dialogue about what is critical to quality for a particular study or development programme, going beyond sole reliance on tools and checklists, is encouraged. Open dialogue can facilitate the development of innovative methods for ensuring quality.”
It elaborates further by stating that “Inflexible, ‘one size fits all’ approaches should be discouraged. Standardised operating procedures are necessary and beneficial for conducting good quality clinical studies, but study specific strategies and actions are also needed to effectively and efficiently support quality in a study.”
ICH E8 R1 October 2021 3.3.2 Focusing on Activities Essential to the Study “Consideration should be given to eliminating nonessential activities and data collection from the study to increase quality by simplifying conduct, improving study efficiency, and targeting resources to critical areas. Resources should be deployed to identify and prevent or control errors that matter.”
ICH E8 R1 October 2021 3.3.4 Reviewing Critical to Quality Factors “Accumulated experience and knowledge, together with periodic review of critical to quality factors should be used to determine whether adjustments to risk control mechanisms are needed, because new or unanticipated issues may arise once the study has begun.”
ICH E6 R3, January 2025 II (Sub-Section 8) Principles of ICH GCP The role of the data management plan, as an example, is captured in this section as having a part to play in documenting operational execution and its feasibility. “The clinical trial protocol as well as the plans or documents for the protocol execution (e.g., statistical analysis plan, data management plan, monitoring plan) should be clear, concise and operationally feasible.”
ICH E6 R3, January 2025 II (Sub-Section 9) Principles of ICH GCP Generating reliable clinical trial results has to be accomplished through systems and processes “that aid in data capture, management and analyses ... that help ensure the quality of the information generated from the trial”, and that these should be fit for purpose. Furthermore, “Computerised systems used in clinical trials should be fit for purpose (e.g., through risk-based validation, if appropriate), and factors critical to their quality should be addressed in their design or adaptation for clinical trial purposes.”
ICH E6 R3, January 2025 3.11.4 Monitoring “The monitoring approach should consider the activities and services involved, including decentralised settings, and be included in the monitoring plan.” Furthermore, “Monitoring activities may include site monitoring (performed on-site or remotely) and centralised monitoring, depending on the monitoring strategy and the design of the clinical trial.” Last but not least, “The appropriate extent and nature of monitoring” should be “based on identified risks. Factors such as the objective, purpose, design, complexity, blinding, number of trial participants, investigational product, current knowledge of the safety profile and endpoints of the trial should be considered.”
ICH E6 R3, January 2025 3.11.4.2 Centralised Monitoring “Centralised monitoring is an evaluation of accumulated data, performed in a timely manner, by the sponsor’s qualified and trained persons (e.g., medical monitor, data scientist/data manager, biostatistician).”
“Centralised monitoring processes provide additional monitoring capabilities that can complement and reduce the extent and/or frequency of site monitoring or be used on its own. Used of centralised data analytics can help identify systemic or site-specific issues, including protocol non-compliance and potentially unreliable data.”
“Centralised monitoring may support the selection of sites and/or processes for targeted site monitoring.”
ICH E6 R3, January 2025 3.11.4.5.4 Monitoring of Clinical Trial Data “Verifying that the investigator is enrolling only eligible trial participants.”
“Checking the accuracy, completeness, and consistency of the reported trial data against the source records and other trial- related records and whether these were reported in a timely manner. This can be done on the basis of using samples and supported by data analytics, as appropriate. The sample size and the types of data or records may need adjustment based on previous monitoring results or other indications of insufficient data quality. Monitoring should:
(i) verify that the data required by the protocol and identified as data of higher criticality in the monitoring plan are consistent with the source;
(ii) identify missing data, inconsistent data, data outliers, unexpected lack of variability and protocol deviations;
(iii) examine data trends, such as the range, consistency and variability of data within and across sites.”
“Identifying significant errors in data collection and reporting at a site or across sites, potential data manipulation and data integrity problems.”
ICH E6 R3, January 2025 3.11.4.6 Monitoring Report “Reports of monitoring activities should include a summary of what was reviewed, a description of significant findings, conclusions and actions required to resolve them and follow-up on their resolution including those resolved in previous reports. The requirements of monitoring reports (including their content and frequency) should be described in the sponsor’s procedures.”
“Reports of investigator site and/or centralised monitoring should be provided to the appropriate sponsor staff as described in the sponsor’s procedures in a timely manner for review and follow up.”
“When needed, the report should describe findings requiring escalation for action and resolution. The sponsor should decide on the appropriate action to be taken, and these decisions and the resolution of the actions involved, where needed, should be recorded.”
ICH E6 R3, January 2025 3.11.4.3 Monitoring Plan “The sponsor should develop a monitoring plan that is tailored to the identified potential safety risks, the risks to data quality and/or other risks to the reliability of the trial results. Particular attention should be given to procedures relevant to participant safety and to trial endpoints. The plan should describe the monitoring strategy, the monitoring activities of all the parties involved, the various monitoring methods and tools to be used, and the rationale for their use. The monitoring strategy should ensure appropriate oversight of trial conduct and consider site capabilities and potential burden. The plan should focus on aspects that are critical to quality. The monitoring plan should reference the sponsor’s applicable policies and procedures.”
MHRA GxP Data Integrity March 2018 2.6 Introduction This guidance aims to promote a risk-based approach to data management that includes data risk, criticality and lifecycle. Users of this guidance need to understand their data processes (as a lifecycle) to identify data with the greatest GXP impact. From that, the identification of the most effective and efficient risk-based control and review of the data can be determined and implemented.
MHRA GxP Data Integrity March 2018 3.6 The principles of data integrity The effort and resource applied to assure the integrity of the data should be commensurate with the risk and impact of a data integrity failure to the patient or environment.
MHRA GxP Data Integrity March 2018 6.15 Data Review and Approval The approach to reviewing specific record content, such as critical data and metadata, cross-outs (paper records) and audit trails (electronic records) should meet all applicable regulatory requirements and be risk-based (…) Data review should also include a risk-based review of relevant metadata, including relevant audit trails records
ICH E6 R3, January 2025 4.2.3 Review of Data and Metadata “Procedures for review of trial-specific data, audit trails and other relevant metadata should be in place. It should be a planned activity, and the extent and nature should be risk-based, adapted to the individual trial and adjusted based on experience during the trial.”
MHRA Oversight and monitoring activities January 2022 N/A Central monitoring of a clinical trial “It is recommended that the data validation activities are recommended to be focused on the data that is critical to the reliability of the trial results as identified by the risk assessment rather than excessive resource spent on raising data queries whose resolution makes little or no impact on the quality of the trial, the safety of the participants and reliability of the results. This is similar to the approach taken for proportionate source data verification (SDV).”

A.2 Fit for Purpose Considerations

Regulation/Guidance Section # Section Name Regulatory Concept
ICH E6 R3 January 2025 N/A GLOSSARY **“Data integrity** includes the degree to which data fulfil key criteria of being attributable, legible, contemporaneous, original, accurate, complete, secure and reliable such that data are fit for purpose.”
ICH E6 R3 January 2025 II (Sub-Section 6) Principles of ICH GCP This section states that “Quality of a clinical trial is considered in this guideline as fit for purpose.”
ICH E6 R3 January 2025 II (Sub-Section 9) Principles of ICH GCP “The quality and amount of the information generated in a clinical trial should be fit for purpose and sufficient to provide confidence in the trial’s results and support good decision making.”
ICH E8 R1 October 2021 2.2 General Principles Section considers Quality of Clinical Studies “as fitness for purpose. The purpose of a clinical study is to generate reliable information to answer the research questions and support decision making while protecting study participants. The quality of the information generated should therefore be sufficient to support good decision making.”
MHRA GxP Data Integrity March 2018 7 Glossary Defines Data Quality as “the assurance that data produced is exactly what was intended to be produced and fit for its intended purpose. This incorporates ALCOA.”

A.3 Data Integrity and Quality

Regulation/Guidance Section # Section Name Regulatory Concept
ICH E8 R1 October 2021 5.7 Study Data Data quality attributes include consistency (uniformity of ascertainment over time), accuracy (correctness of collection, transmission, and processing), and completeness (lack of missing information).
MHRA GxP Data Integrity March 2018 2.7 Introduction States that data integrity is not data quality as “the controls required for integrity do not necessarily guarantee the quality of the data generated.”
MHRA GxP Data Integrity March 2018 6.4 Definition of terms and interpretation of requirements Data integrity is the degree to which data are complete, consistent, accurate, trustworthy, reliable and that these characteristics of the data are maintained throughout the data life cycle. The data should be collected and maintained in a secure manner, so that they are attributable, legible, contemporaneously recorded, original (or a true copy) and accurate. Assuring data integrity requires appropriate quality and risk management systems, including adherence to sound scientific principles and good documentation practices.
MHRA GxP Data Integrity March 2018 4.4 Establishing data criticality and inherent integrity risk Reduced effort and/or frequency of control measures may be justified for data that has a lesser impact to product, patient or the environment if those data are obtained from a process that does not provide the opportunity for amendment without high-level system access or specialist software/knowledge.
MHRA Oversight and monitoring activities January 2022 N/A The importance of accuracy of the clinical trial data “It is not the accuracy of the individual trial data that is important, but the reliability and robustness of the trial results.”
MHRA Oversight and monitoring activities January 2022 N/A The importance of accuracy of the clinical trial data “The aim of the management, monitoring and data management activities is recommended to focus on the data and activities that are critical to the reliability of the trial results, for example, the endpoint for the primary objective of the trial or key design aspects (e.g., randomisation) These would be identified during a risk assessment of the trial. It is recommended to aim for a high level of accuracy in these areas identified and potentially accept some degree of error in other areas. Consideration for defining such acceptability in terms of tolerance limits is recommended.”

A.4 Quality by Design (QbD)

Regulation/Guidance Section # Section Name Regulatory Concept
ICH E8 R1 October 2021 2.2 General Principles Quality by Design (QbD) “in clinical research sets out to ensure that the quality of a study is driven proactively by designing quality into the study protocol and processes. This involves the use of a prospective, multidisciplinary approach to promote the quality of protocol and process design in a manner proportionate to the risks involved, and clear communication of how this will be achieved.”
ICH E8 R1 October 2021 3 Designing Quality into Clinical Studies “Quality by design involves focusing on critical to quality factors to ensure the protection of the rights, safety, and wellbeing of study participants, the generation of reliable and meaningful results, and the management of risks to those factors using a risk-proportionate approach. The approach is supported by the establishment of an appropriate framework for the identification and review of critical to quality factors at the time of design and planning of the study, and throughout its conduct, analysis, and reporting.”
ICH E8 R1 October 2021 3.1 Quality by Design of Clinical Studies “The likelihood that a clinical study will answer the research questions while preventing important errors can be dramatically improved through prospective attention to the design of all components of the study protocol, procedures, associated operational plans and training.” The paragraph continues in questioning the robustness of traditional processes, mentioning that “activities such as document and data review and monitoring, where conducted retrospectively, are an important part of a quality assurance process; but, even when combined with audits, they are not sufficient to ensure quality of a clinical study.”
ICH E8 R1 October 2021 3.1 Quality by Design of Clinical Studies Concludes by stating that “Good planning and implementation of a clinical study also derive from attention to the design elements of clinical studies.”
MHRA Oversight and monitoring activities January 2022 N/A The importance of accuracy of the clinical trial data “The design of the trial can assist in reducing or mitigating the impact of missing or incorrect data, for example, the results of large blinded, randomised trials with high power are unlikely to be affected by increased variability/omissions of the data, particularly as the errors/omissions would not be differential on a treatment basis (biased).
Small blinded and randomised trials may suffer from reduced power with increased data variability/omissions and there is potential to increase the risk of a false negative result. Open trials are more at risk from bias, as errors and omissions could be potentially differential for the treatment groups. This issue is recommended to be evaluated as part of the risk assessment to determine what level of SDV (and other monitoring checks) is needed to mitigate any concerns about the reliability of the trial results.”

A.5 Critical Data, Processes and Critical to Quality (CtQ) Factors

Regulation/Guidance Section # Section Name Regulatory Concept
FDA, April 2023, RBM Q&A II Background “FDA recommends that at the protocol design stage, sponsors identify the critical data and processes necessary for human subject protection and maintaining data integrity for the investigation.”
ICH E6 R3 January 2025 I Introduction “Clinical trials vary widely in scale, complexity and cost. Careful evaluation of critical to quality factors involved in each trial and the risks associated with these factors will help ensure efficiency by focusing on activities critical to achieving the trial objectives.”
ICH E6 R3 January 2025 3.11.4.3 Monitoring Plan “Monitoring of important data and processes (e.g., those related to primary endpoints and key secondary endpoints and processes intended to ensure participant safety) performed outside the investigator site (e.g., central image reading facilities, central laboratories) should be addressed in the monitoring plan.”
ICH E8 R1 October 2021 3.2 Critical to Quality Factors Critical to Quality Factors are defined as “attributes of a study whose integrity is fundamental to the protection of study participants, the reliability and interpretability of the study results, and the decisions made based on the study results. These quality factors are considered to be critical because, if their integrity were to be undermined by errors of design or conduct, the reliability or ethics of decision-making based on the results of the study would also be undermined.” …
“Having identified those factors, it is important to determine the risks that threaten their integrity and decide whether they can be accepted or should be mitigated, based on their probability, detectability and impact.”
ICH E8 R1 October 2021 3.2 Critical to Quality Factors Elaborates on the risk of striving for perfection instead of focusing on what matters by stating “Perfection in every aspect of an activity is rarely achievable or can only be achieved by use of resources that are out of proportion to the benefit obtained. The quality factors should be prioritised to identify those that are critical to the study, at the time of the study design, and study procedures should be proportionate to the risks inherent in the study and the importance of the information collected.”
…
“The critical to quality factors should be clear and should not be cluttered with minor issues (e.g., due to extensive secondary objectives or processes/data collection not linked to the proper protection of the study participants and/or primary study objectives).” This is the genesis of risk-based approaches where focus on critical data and process is paramount.
ICH E8 R1 October 2021 3.3 Approach to Identifying the Critical to Quality Factors Provides further guidance to Clinical Data Managers when designing data collection solutions by stating that “Study designs should be operationally feasible and avoid unnecessary complexity. Protocols and case report forms/data collection methods should enable the study to be conducted as designed and avoid unnecessary data collection.”
ICH E8 R1 October 2021 5.7 Study Data Data quality attributes include consistency (uniformity of ascertainment over time), accuracy (correctness of collection, transmission, and processing), and completeness (lack of missing information). These aspects should be proactively considered during study planning by identifying the factors, critical to the quality of the study, associated with data sourcing, collection, and processing.
ICH E6 R3 January 2025 3.10 Quality Management This section now references ICH E8 (R1) for description of critical to quality factors “likely to have a meaningful impact on participant’s rights, safety and well-being and the reliability of the results.”
MHRA GxP Data Integrity March 2018 4.1 Establishing data criticality and inherent integrity risk Data has varying importance to quality, safety and efficacy decisions. Data criticality may be determined by considering how the data is used to influence the decisions made.
MHRA Oversight and monitoring activities January 2022 N/A The importance of accuracy of the clinical trial data “The aim of the management, monitoring and data management activities is recommended to focus on the data and activities that are critical to the reliability of the trial results, for example, the endpoint for the primary objective of the trial or key design aspects (e.g., randomisation).”

A.6 Risk Management

Regulation/Guidance Section # Section Name Regulatory Concept
MHRA Risk-Adapted approach January 2022 N/A Risk Assessment “It is recommended that a risk assessment is undertaken for all clinical trials. Identification of potential risks to trial participants and to the reliability of the trial results on a trial basis and taking actions to mitigate those risks can only be beneficial for the quality of any clinical trial.”
MHRA Risk-Adapted approach January 2022 N/A When and how to undertake the risk assessment “The risk assessment should be done as early as possible.”
MHRA Risk-Adapted approach January 2022 N/A When and how to undertake the risk assessment “The relevant personnel undertaking the risk assessment would typically include a medic with understanding of the therapeutic area and the therapeutic use of the proposed investigational medicinal products (IMP);…a statistician with relevant experience of medical statistics and a person with an appropriate level of understanding of applicable regulatory, legal and GCP requirements.”
“In addition, it would be usual to include data management personnel, trial monitors or project/study managers in the multidisciplinary team conducting the risk assessment, as these individuals would be important with respect to defining feasible mitigation/adaptations… it may be considered appropriate by the sponsor to include a suitable patient advocate/representative in the risk assessment.”
ICH E6 R3 January 2025 3.10.1.1 Risk Identification “The sponsor should identify risks that may have a meaningful impact on critical to quality factors prior to trial initiation and throughout trial conduct. Risks should be considered across the processes and systems, including computerised systems, used in the clinical trial (e.g., trial design, participant selection, informed consent process, randomisation, blinding, investigational product administration, data handling and service provider activities).”
ICH E6 R3 January 2025 3.10.1.2 Risk Evaluation “The sponsor should evaluate identified risks and existing controls in place to mitigate the risk by considering
(a) The likelihood of harm/hazard occurring.
(b) The extent to which such harm/hazard would be detectable.
(c) The impact of such harm/hazard on trial participant protection and the reliability of trial results.”
ICH E6 R3 January 2025 3.10.1.3 Risk Control “Risk control should be proportionate to the importance of the risk to participants’ rights, safety and well-being and the reliability of trial results. Risk mitigation activities may be incorporated, for example, in protocol design and implementation, monitoring plans, agreements between parties defining roles and responsibilities, and training.”
ICH E6 R3 January 2025 3.10.1.3 Risk Control “Where relevant, the sponsor should set pre-specified acceptable ranges (e.g., quality tolerance limits at the trial level) to support the control of risks to critical to quality factors. These pre-specified ranges reflect limits that when exceeded have the potential to impact participant safety or the reliability of trial results. Where deviation beyond these ranges is detected, an evaluation should be performed to determine if there is a possible systemic issue and if action is needed.”
ICH E6 R3 January 2025 3.10.1.4 Risk Communication Rights, safety or well-being of trial participant(s). “The sponsor should document and communicate the identified risks and mitigating activities, if applicable, to those who are involved in taking action or are affected by such activities. Communication also facilitates risk review and continual improvement during clinical trial conduct.”
ICH E6 R3 January 2025 3.10.1.5 Risk Review “The sponsor should periodically review risk control measures to ascertain whether the implemented quality management activities remain effective and relevant, taking into account emerging knowledge and experience. Additional risk control measures may be implemented as needed.”
ICH E6 R3 January 2025 3.10.1.6 Risk Reporting “The sponsor should summarise and report important quality issues (including instances in which acceptable ranges are exceeded, as detailed in section 3.10.1.3) and the remedial actions taken and document them in the clinical trial report (see ICH E3).”
ICH E6 R3 January 2025 3.12.2 Noncompliance “If noncompliance that significantly affects or has the potential to significantly affect the rights, safety or well-being of trial participant(s) or the reliability of trial results is discovered, the sponsor should perform a root cause analysis, implement appropriate corrective and preventive actions and confirm their adequacy unless otherwise justified.”
MHRA GxP Data Integrity March 2018 3.4 The principles of data integrity “Organisations are expected to implement, design and operate a documented system that provides an acceptable state of control based on the data integrity risk with supporting rationale. An example of a suitable approach is to perform a data integrity risk assessment (DIRA) where the processes that produce data or where data is obtained are mapped out and each of the formats and their controls are identified and the data criticality and inherent risks documented.”
MHRA GxP Data Integrity March 2018 4.5 Establishing data criticality and inherent integrity risk “The data integrity risk assessment (or equivalent) should consider factors required to follow a process or perform a function. It is expected to consider not only a computerised system but also the supporting people, guidance, training and quality systems.”
“Therefore, automation or the use of a ‘validated system’ (e.g., e-CRF; analytical equipment) may lower but not eliminate data integrity risk. Where there is human intervention, particularly influencing how or what data is recorded, reported or retained, an increased risk may exist from poor organisational controls or data verification due to an overreliance on the system’s validated state.”
FDA, April 2023, RBM Q&A N/A Question 7 “Significant issues should be thoroughly evaluated in a timely manner at the appropriate levels (for example, sponsor, clinical sites) as described in the monitoring plan. A root cause analysis followed by appropriate corrective and preventive actions should be undertaken promptly to reduce the impact of the identified issue on the rights, safety, and welfare of participants in the clinical investigation and/or the integrity of the data.”
FDA, April 2023, RBM Q&A N/A Question 7 “Significant issues identified through monitoring and oversight activities and the actions to be taken should be documented and communicated to the appropriate parties, which may include, but are not limited to (1) sponsor management; (2) sponsor teams; (3) clinical sites; (4) institutional review boards; (5) other relevant parties (for example, DMCs and relevant contract research organizations); and (6) applicable regulatory agencies, including FDA, when appropriate.”

Appendix B: rb-CDM Study Design Process Checklist for CDM Experts

Risk Identification, Operational Feasibility and Risk Assessment

  1. Engage stakeholders and align on protocol design

  2. Identify and document critical to quality (CtQ) factors

  3. Conduct study risk assessment

Protocol de-risking

Define mitigations and surveillance plans for remaining risks

  1. Design data review and validation strategy

  2. Define quality control and risk mitigation plan

  3. Specify reporting and analytics requirements

Implement risk control strategies

Additional considerations

  1. Define milestones-based deliverables and compliance monitoring

  2. Conduct knowledge transfer and secure CRO collaboration

Appendix C: rb-CDM Study Execution Process Checklist for CDM Experts

Monitor, document and address observed risks

  1. Conduct tailored data review proportional to risks

  2. Review critical data and associated metadata

  3. Monitor for the possible emergence of any new risks

  4. Monitor critical processes during study execution

  5. Ensure synergetic oversight across stakeholders

Adapt by maintaining dynamic risk management

  1. Regularly review and update the risk assessment, risk monitoring and mitigation strategies

Protocol Amendments

  1. Continuous review and protocol amendments

Appendix D – rb-CDM Study Close-Out Checklist for CDM Experts

Conduct a final risk evaluation

  1. Perform a final review of all occurrences of issues related to CtQ factors

  2. Conduct a final data quality assessment focused on CtQ factors

  3. Ensure newly identified risks are mitigated

Assess remaining outstanding issues

  1. Review and close outstanding issues (new and outstanding)

  2. Document process completion and compliance

Adapt Processes and Systems based on Lessons learned

  1. Assess CAPA outcome to evaluate need to adapt organizational level practices

Acknowledgements

We would like to acknowledge the valuable contributions of Cheryl Grandinetti (FDA) and Steve Young (CluePoints), whose input and support greatly assisted the development of this chapter.

Literature Review

Due to the evolving ongoing work on Risk-Based CDM, there was no literature search and review done for this chapter.

Revision History

Publication Date Comments
September 2025 Final DRAFT for public review
April 2026 Post Public review Version

Competing Interests

The authors have no competing interests to declare.

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